HYUNDAI HEAVY INDUSTRIES CO. LTD.,DEHRADUN vs. JCIT, DEHRADUN

In the result, the appeal of the assessee is allowed partly for statistical purposes

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2010-11 Hyundai Heavy Industries Co. Vs. Jcit, International Tax Taxation, Ltd., C/O- M/S. Hemant Arora & Dehradun. Co. 1, Tyagi Road, Dehradun (Pan: Aaach5727Q) (Appellant) (Respondent)

5A of the Agreement, which is placed before the Hon’ble Bench. The contract between two unrelated parties, which describes the operator’s obligations therein. The Contract dated 15.5.1997 for ‘Operation and Maintenance’, of the Power Plant is in two parts:- i) Operations & Maintenance Services (including supply of locally available parts and material) to be rendered by Chennai

YOUNG INDIAN,NEW DELHI vs. ACIT(E), NEW DELHI

Bench: Shri Anil Chaturvedi & Shri Amit Shukla(Through Video Conference)

5A Herald House, since inception. 23.11.2010 Commencement of He held 550 shares in YI, which directorship of Mr. were later on, were transferred Sam Pitroda to Mr. Oscar Fernandes. He was Director of AJL since 21.12.2010 23.11.2010 Commencement of He held 550 shares in YI directorship of Mr. which were later on transferred Suman Dubey to Mrs. Sonia Gandhi

MAHASHIAN DI HATTI (P) LTD,NEW DELHI vs. PCIT-4, NEW DELHI

In the result, Appeal of the Assessee is allowed

5A & 5B, it has been observed\nthat there have been sharp increase of Rs.14,49,91,615/- under the sub-head\n\"Advance for properties\" and Rs.42,85,51,442/- under sub-head \"Advance to\nsuppliers\". During the course of assessment proceedings, the FAU has not\nexamined the business purposes of the aforesaid advances and hence, FAU has not\nmade

GULSHAN HOMES AND INFRASTRUCTURE (P) LTD,NEW DELHI vs. DR. MANOJ KUMAR, DCIT, CENTRAL CIRCLE-31, NEW DELHI

In the result, the appeal of the assessee is partly allowed

section 132 of the Act was conducted on 6-1-2021\non the premises of Hans Group and one Shri Parveen K Jain, wherein various\nincriminating materials and papers/ documents/ digital data were seized including\ncertain WhatsApp chats and a hand written \"Interest Account\" sheet dated\nNovember 2019 were extracted from the mobile phone of Mr. Parveen Jain. The income

DCIT, NEW DELHI vs. M/S. PACL LTD., NEW DELHI

In the result, appeal filed by the Revenue is dismissed

Bench: the Hon'ble ITAT, however, Assessing Officer rejected the same and proceeded to levy penalty u/s 271(1)(c) of the Act amounting to Rs.12,51,51,671/- which is 100% of the tax sought to be evaded.

Section 271(1) (c) could be levied because of the deeming DCIT vs. M/s PACL Ltd. provision mentioned in these two explanations. In this particular case no such search was carried out and therefore Explanation-5 and 5a have no application. Therefore in respect of these 35 crores the penalty proceedings are required to be dropped as there

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A .No. 467/Del/2014 (A.Y 2009-10)

TDS credit of Rs.17,21,027/-. The Assessing Officer completed the assessment vide order dated 02.01.2014. The Assessing Officer made various additions amounting of Rs. 2071,04,18,575/-. 4. Being aggrieved by the same, the Assessee filed this appeal. 5. Ground No. 1 to 2 are general in nature as per submissions of the Ld. AR, therefore, the same

YOUNG INDIAN,NEW DELHI vs. ADDL. CIT (INV.), NEW DELHI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri R. K. Panda & Ms. Suchitra Kambleassessment Year : 2011-12 Young Indian, Addl. Dit (Inv.), Unit- 4, 5A, Herald House, New Delhi. Bahadur Shah Zafar Marg, Vs. New Delhi.

5A, Herald House, New Delhi. Bahadur Shah Zafar Marg, Vs. New Delhi. PAN : AAACY4625Q (Appellant) (Respondent) Assessee by : Shri Yogesh Thar, CA Shri Ankit Agarwal, CA : Shri S.S. Rana, CIT-DR Department by Date of hearing : 19-06-2018 Date of pronouncement : 30-08-2018 O R D E R PER R. K. PANDA, AM : This appeal filed

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 9(1)(vi) of the Act brought into force by the Finance Act, 2012 are applicable to domestic laws and the said amended definition cannot be extended to DTAA, where the term has been defined originally and not amended." xxxx xxxx xxxx 26. In view of the above said facts, we hold that there is no merit

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purposes

Bench: Shri N.K. Saini & Shri K.N. Charry

TDS of Rs. 25,66,500/- excluding income from the sales tax subsidy being capital receipt and expenditure/loss on Mark-to-market of derivative contracts and including expenditure on lumpsum royalty paid during the year. 2.1. In respect of royalty for use of brand name and AMP services, reference was made to the Transfer Pricing Officer u/s 92CA

VIDYA EDUCATION INVESTMENTS PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result, appeal of assessee is partly allowed

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

TDS challan, in respect of audit fee paid. The assessee requested for admission of the additional evidence, on which, report from the A.O. was called for. Ld. CIT(A) ultimately admitted these additional evidence under Rule 46A. 7. The Ld. CIT(A) noted the facts in the case of assessee that assessee purchased 39 acres of land in Lonavala

KAMLA DEVI,HISAR vs. ITO,WARD-5, HISAR

In the result appeal of the assessee is allowed

TDS, Rajkot Vs. Muktanandgiri Maheshgiri in Civil Appeal No. 18475 of 2017 (Arising out of SLP (C)No. 27333 of 2017), judgement dated November 10,2017; (vi) Decision of the Hon’ble ITAT New Delhi ‘F’ Bench in the case of Paramjeet Singh vs. ACIT, Circle Karnal in ITA No.1393/DEL/2017 (A.Y 2011-12) order dated 16.04.2021; (vii) Decision

BRAHMA CENTER DEVELOPMENT PVT. LTD.,NEW DELHI vs. PR. CIT-02, NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri R.K. Panda & Shri K.Narasimha Chary

5A, 10th Floor, New Delhi DLF Cyber City, Phase-II, Gurgaon. PAN :AAECB1294N Appellant Respondent Assessee by Sh. Salil Kapoor, Adv. Ms. Ananya Kapoor, Adv. Revenue by Sh. S.S. Rana, CIT/DR Date of Hearing 12/12/2019 Date of Pronouncement 18/12/2019 ORDER PER K. NARASIMHA CHARY, JM Aggrieved by the orders dated 28.03.2019 passed u/s. 263 of the Income